Omar Folk, a federal prisoner serving a 264-month sentence for drug and firearms offenses, previously filed a habeas petition under 28 U.S.C. § 2241 in 2022. That petition raised a conditions-of-confinement claim regarding the threat of COVID-19, which the District Court denied. Folk later attempted to reopen the case, first arguing the District Court had mischaracterized his claim as a request for home confinement under the CARES Act rather than a general conditions claim, and second, in May 2025, arguing that the Supreme Court's decision in Loper Bright v. Raimondo provided grounds to reopen his case. Folk contended that under Loper Bright, the District Court should no longer accord deference to the Bureau of Prisons' determination that he was ineligible for home confinement under the Second Chance Act and the First Step Act. The District Court denied the motion, and the Third Circuit summarily affirmed.
The Third Circuit reviewed the denial of the Rule 60(b)(6) motion for abuse of discretion, noting that such relief is available only in cases evidencing extraordinary circumstances. The court concluded that the District Court did not abuse its discretion in denying the motion. The court reasoned that Folk's claims under the Second Chance Act and the First Step Act were wholly unrelated to the conditions-of-confinement claim in his original § 2241 petition or his prior Rule 60(b) motion. The court emphasized that proffering an entirely new theory after dismissal is inappropriate for a Rule 60(b) motion. While acknowledging that Loper Bright requires courts to exercise independent judgment in deciding whether an agency has acted within its statutory authority, the court found that this change in administrative law principles did not constitute the extraordinary circumstances necessary to reopen a final judgment regarding a claim that was already adjudicated on different grounds.
The decision reinforces the high bar for reopening final judgments under Rule 60(b)(6). Prisoners cannot use the Loper Bright decision as a blanket mechanism to relitigate habeas claims based on new administrative law theories if those theories were not part of the original proceeding. The case is remanded to the District Court with instructions to maintain the denial of the motion, leaving the original conditions-of-confinement judgment intact. The ruling clarifies that a change in the standard of review for agency deference does not automatically constitute an extraordinary circumstance warranting relief from a final judgment.
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